CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD. Vs. THE DEPUTY COMMISSIONER OF INCOME TAX, LARGE TAX PAYER UNIT AND ORS.

JUDGEMENT

(1.) In all these appeals, filed by the assessees under Sec. 260A of the Income-tax Act, 1961 ("the Act" for brevity), who are Insurance Companies, viz., United India Insurance Company Limited, Cholamandalam MS General Insurance Company Limited, and Royal Sundaram General Insurance Company Limited, the challenge is to the common order passed by the Income-tax Appellate Tribunal 'A' Bench, Chennai ("the Tribunal" for brevity), in I.T.A.No.2276/Chny/2014, dtd. 31/7/2018, for the assessment year 2009-10;

(2.) The common legal issue arising in these appeals relates to disallowance of reinsurance premium ceded to non-resident reinsurers. The assessees have raised the following substantial questions of law for consideration:-

(3.) We have elaborately heard Mr.R.V.Eshwar, learned Senior Counsel for M/s.United India Insurance Company Limited; Mr.Percy Pardiwallia, learned Senior Counsel for M/s.Cholamandalam MS General Insurance Company Limited, and M/s.Royal Sundaram General Insurance Company Limited; and Mr.M.Swaminathan, learned Senior Standing Counsel and Mrs.V.Pushpa, learned Junior Standing Counsel for the respondent/Revenue.